CP25/23: Deferred Payment Credit (unregulated Buy Now Pay Later): proposed approach to regulation

Consultation published
18/07/2025
18/07/2025
Consultation closes
26/09/2025

We’re seeking feedback on rules and guidance that we propose to apply to Deferred Payment Credit (DPC) lending, often known as Buy Now Pay Later, following the Government’s decision to bring this under our regulation. 

Read CP25/23 (PDF)

Why we are consulting

DPC has been more commonly known as Buy Now Pay Later (BNPL).

DPC refers to an interest-free credit product, repayable in 12 or fewer instalments in 12 months or less and which is currently exempt from regulation. We refer to the product as DPC as this is the name given to it in the legislation that will bring it into regulation.

In addition, we already have rules for other regulated credit agreements with Buy Now Pay Later offers, for which we use the term BNPL. These are distinct from DPC.

On 14 July 2025, the Government legislated to bring DPC lending under our regulation.

From 15 July 2026, lenders who offer a DPC agreement to finance the purchase of goods or services from a merchant will come under our regulation. Merchants that offer their own DPC agreements directly will not. Nor will the broking of DPC agreements.

We’re now consulting on rules and guidance for the DPC sector. This includes proposals for firms to give information to consumers and undertake creditworthiness assessments, and whether we should apply existing rules for regulated credit activity to this sector.

Who this is for

  • DPC lenders.
  • Consumer groups and organisations.
  • DPC consumers.
  • Merchants who offer DPC from a third-party lender as a payment option.
  • Industry groups and trade bodies.

Next steps

We’re asking for comments on this Consultation Paper by 26 September 2025.

You can send them to us using our online response form:

Online response form

By writing to: Consumer Finance Policy Team, Financial Conduct Authority, 12 Endeavour Square, London E20 1JN.

Or by emailing: [email protected].

We’ll continue to engage with DPC lenders, consumer organisations and other stakeholders through the consultation process. We plan to issue a policy statement with final rules in early 2026.  

Background

DPC lending has grown from £0.06bn in 2017 to over £13bn in 2024.

When they work well, DPC products give consumers access to credit that is affordable, and offer a convenient way to spread payment for goods and services.

DPC is currently exempt from regulation. But there are concerns that this may result in borrowers not getting sufficient information about DPC agreements and some lending being unaffordable.  

In line with our strategy (PDF), our approach seeks to help consumers navigate their financial lives while supporting sustained economic growth. Our proposals aim to ensure that DPC borrowers get the right information, in the right way and at the right time.